On December 30, 2013, the Internal Revenue Service issued much anticipated guidance, in the form of Revenue Procedure 2014-12, providing a safe harbor under which it will not challenge a partnership’s allocations of rehabilitation tax credits to its partners. Because Revenue Procedure 2014-12 is similar to Revenue Procedure 2007-65, which established a safe harbor for the allocation of production tax credits by wind partnerships, the two revenue procedures are compared below.

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